dws
3 days ago
InterDigital Wins Two CSI Awards for Best Immersive Video and Video Processing Technology
Company Release - 9/16/2024
InterDigital awarded for contributions to MPEG immersive standards and Advanced HDR solutions
WILMINGTON, Del., Sept. 16, 2024 (GLOBE NEWSWIRE) -- InterDigital, Inc. (Nasdaq: IDCC), a mobile, video and AI technology research and development company, was awarded two CSI Awards recognizing excellence in video processing solutions and the delivery of immersive video experiences. The CSI awards, organized by the Cable and Satellite International (CSI) Magazine, recognize innovation and excellence in the cable, satellite, broadcast, IPTV, telco, broadband/OTT video, mobile TV and associated sectors. The annual awards are presented at the International Broadcasting Convention (IBC) and were announced on September 13, 2024.
“The prestigious CSI Awards have recognized the impact of our foundational research on immersive video and HDR solutions, and I congratulate our team of engineers and inventors who made this recognition possible,” said Chief Technology Officer Rajesh Pankaj. “These awards are a testament to the caliber of our research and innovation impact across the industry.”
In the category of Best Immersive Video, InterDigital was awarded for cutting-edge video innovation and contributions to MPEG immersive standards that play a significant role in ensuring interoperability across immersive experiences, maintaining data rates that are sustainable, and innovating solutions to deliver immersive experiences at scale. The MPEG Visual Volumetric Video-based Coding (V3C) standard defines the general mechanism for coding and streaming volumetric content through two main codecs: Video-based Point Cloud Compression (V-PCC) and MPEG Immersive Video (MIV). InterDigital is a leading contributor to both codecs, which can be applied across a variety of immersive-enhanced experiences, from entertainment, to telelearning, and increasingly to the delivery of live and esports, with assurance that the content can be enjoyed efficiently and seamlessly at scale across a variety of devices. InterDigital is also a pioneer in the MPEG-I Haptics standard, which will outline how to create, stream, and render haptic content at scale, and is exploring how to translate and distribute large scale haptic-enhanced immersive video experiences to audiences with varying device capabilities and requirements.
In the category of Best Video Processing Technology, InterDigital was awarded for contributions to Advanced HDR by Technicolor solutions that optimize HDR technology for OTT streaming by providing a superior viewing experience without increasing processing and bandwidth requirements. A collaboration between InterDigital, Philips and Technicolor, Advanced HDR by Technicolor is a suite of high dynamic range (HDR) production, distribution and display solutions that leverage machine learning to maximize the image quality of any HDR format. Ensuring legacy SDR content meets modern HDR standards, InterDigital contributes to Advanced HDR capabilities that empower seamless integration of SDR and HDR content into a single workflow, while reducing costs through automatic conversion.
To learn more about the 2024 CSI Award winners, please click here.
dws
3 days ago
InterDigital Announces Annual Recurring Revenue Target Of $1 Billion By 2030
Company Release - 9/16/2024
WILMINGTON, Del., Sept. 16, 2024 (GLOBE NEWSWIRE) -- InterDigital, Inc. (Nasdaq: IDCC), a mobile, video and AI technology research and development company, has announced targets of $1 billion in annual recurring revenue and $600 million in adjusted EBITDA by 2030.
“In the past four years, we have almost doubled our revenue, improved our execution across the business, and taken multiple steps to enhance shareholder value,” noted Liren Chen, President and CEO, InterDigital. “Based on our world-class innovation in wireless, video and AI, accelerating momentum across the business, the large addressable markets available to us, and new greenfield opportunities, we believe we are perfectly positioned to deliver significant growth in revenue and profitability in coming years.”
InterDigital’s executive team announced and discussed the new targets at a recent investor day. Links to investor day materials can be found below:
The presentation is here.
A full replay is here.
About InterDigital®
InterDigital is a global research and development company focused primarily on wireless, video, artificial intelligence (“AI”), and related technologies. We design and develop foundational technologies that enable connected, immersive experiences in a broad range of communications and entertainment products and services. We license our innovations worldwide to companies providing such products and services, including makers of wireless communications devices, consumer electronics, IoT devices, cars and other motor vehicles, and providers of cloud-based services such as video streaming. As a leader in wireless technology, our engineers have designed and developed a wide range of innovations that are used in wireless products and networks, from the earliest digital cellular systems to 5G and today’s most advanced Wi-Fi technologies. We are also a leader in video processing and video encoding/decoding technology, with a significant AI research effort that intersects with both wireless and video technologies. Founded in 1972, InterDigital is listed on Nasdaq.
InterDigital is a registered trademark of InterDigital, Inc.
For more information, visit the InterDigital website: www.interdigital.com.
Forward-Looking Statements
This press release contains forward-looking statements within the meaning of Section 21E of the Securities Exchange Act of 1934, as amended. Such statements include information regarding our current beliefs, plans and expectations. Words such as “believe,” “anticipate,” “estimate,” “expect,” “project,” “intend,” “plan,” “forecast,” “goal,” “could,” "would," "should," "if," "may," "might," "future," "target," "trend," "seek to," "will continue," "predict," "likely," "in the event," and variations of any such words or similar expressions are intended to identify such forward-looking statements.
Forward-looking statements are made on the basis of management’s current views and assumptions and are not guarantees of future performance. Forward-looking statements are inherently subject to risks and uncertainties that could cause actual results, and actual events that occur, to differ materially from results contemplated by the forward-looking statements. These risks and uncertainties include, but are not limited to: (i) unanticipated delays, difficulties or accelerations in the execution of patent license agreements; (ii) the resolution of current legal proceedings, including any awards or judgments relating to such proceedings, additional or related legal proceedings, including appeals, changes in the schedules or costs associated with such proceedings or adverse rulings; (iii) our ability to leverage our strategic relationships and secure new patent license agreements on acceptable terms; (iv) our ability to enter into sales and/or licensing partnering arrangements for certain of our patent assets; (v) our ability to expand our revenue opportunities by entering into licensing arrangements with video streaming and other cloud-based service providers; (vi) our ability to enter into partnerships with leading inventors and research organizations; (vii) our ability to identify and pursue strategic acquisitions of technology and patent portfolios and other strategic growth opportunities; (viii) our ability to commercialize our technologies and enter into customer agreements; (ix) the failure of the markets for our current or new technologies to materialize to the extent or at the rate that we expect; (x) our continued ability to develop new technologies and secure new patents, including the risk of unexpected delays or difficulties related to the development of our technologies; (xi) risks associated with our capital allocation strategies, including risks associated with our planned dividend payments and share repurchases; (xii) changes in our interpretations of, and assumptions and calculations with respect to the impact on us of, the 2017 Tax Cuts and Jobs Act, as well as further guidance that may be issued regarding such act; (xiii) risks related to the potential impact of new accounting standards on our financial position, results of operations or cash flows; (xiv) failure to accurately forecast the impact of our restructuring activities on our financial statements and our business; (xv) the timing and impact of potential regulatory, administrative and legislative matters; (xvi) changes or inaccuracies in market projections; (xvii) our ability to obtain liquidity though debt and equity financings; (xviii) the potential effects that macroeconomic uncertainty could have on our financial position, results of operations and cash flows; (xix) impacts from acts of terrorism, war or political or civil unrest, or any responses thereto, in the United States or elsewhere; (xx) changes in our business strategy; (xxi) changes or inaccuracies in our expectations with respect to royalty payments by our customers and (xxii) risks related to our assumptions and application of relevant accounting standards, including with respect to revenue recognition.
We undertake no duty to revise or update publicly any forward-looking statement for any reason, except as otherwise required by law.
InterDigital Contact:
InterDigital Investor Relations
Email: investor.relations@interdigital.com
+1 (302) 300-1857
dws
1 week ago
At 6GSymposium, InterDigital to Lead Crucial Discussions on Emerging Use Cases and Avenues Towards 6G Profitability
Company Release - 9/9/2024
CTO Rajesh Pankaj and Head of Wireless Labs Milind Kulkarni among speakers as InterDigital returns as Symposium partner
WILMINGTON, Del., Sept. 09, 2024 (GLOBE NEWSWIRE) -- InterDigital, Inc. (Nasdaq: IDCC), a mobile, video and AI technology research and development company, announced its return to the 6GSymposium alongside partners Northeastern University Institute for the Wireless Internet of Things, Next G Alliance, and host 6GWorld. InterDigital is a founding partner of the 6GSymposium, which is now in its fifth year. The 2024 Fall Symposium focuses on “Crucial Conversations” and invites leaders in technology, policy, and business to discuss the fundamental issues facing 6G development, including the value it can create and where it is best applied.
The 6GSymposium will take place in Washington, D.C. on September 23 - 24 and will feature executive and expert panel discussions with industry leaders, including InterDigital CTO Rajesh Pankaj and Head of Wireless Labs Milind Kulkarni. Doug Castor, InterDigital’s Senior Director and Head of Wireless Research will introduce a keynote session exploring the most compelling use cases for the ‘next G’ and participate in a panel exploring the global standards ushering in new wireless capabilities and services.
The following details InterDigital’s participation in the Symposium.
Monday, September 23
What’s The Most Compelling Use Case for the Next G? 1:00 – 2:00
InterDigital’s Doug Castor will introduce this keynote conversation featuring perspectives from FCC Commissioner Geoffrey Starks, Nokia President of Bell Labs Core Research Peter Vetter, ATIS VP of Technology Policy and Government Affairs David Young, and TIA CEO David Stehlin on the possible avenues to make 6G more likely to be important and useful to end users. More here.
How Do We Make the 6G Transformation Profitable? 3:30 – 4:30
In a panel discussion exploring the avenues to ensure the 5G to 6G transition is one of technical and commercial growth, InterDigital’s Rajesh Pankaj will share insights on the role of innovation and standardization to enhance the ROI for 6G and will speak alongside industry executives including Rakuten Symphony CMO Geoff Hollingworth, Accenture Cloud First Chief Strategy Officer Jefferson Wang, and Echostar CTO Eben Albertyn. The panel will be moderated by More with Mobile Founder Ken Figueredo. More here.
Tuesday, September 24
New Features to Enable New Markets 11:30 – 1:00
The success of a 6G-era cellular market is likely to demand new services that have not been seen in prior generations and will depend on key technology enablers for growth. In this session, InterDigital’s Milind Kulkarni will share his expertise on emerging 6G features and capabilities, alongside industry experts Diane Rinaldo, Executive Director of the Open RAN Policy Coalition, Ray Dolan, CEO of Cohere Technologies, and Mark Kahn, Senior Fellow and Principal Investigator for 5G.Mil at Lockheed Martin. The discussion will be moderated by Ian Wong, Senior Director in the Office of the CTO at Viavi. More here.
A Global Next G: Global Standards, Global Services? 2:45 – 3:30
While institutions like the ITU and 3GPP present a global standards framework to usher in new generations of communications capabilities, countries around the world are exploring distinct agendas and avenues to leverage the possibilities of a ‘global’ 6G. InterDigital’s Doug Castor, Co-Chair of the ATIS Next G Alliance Steering Group, will join Bharat 6G Alliance Board Member Kiran Kuchi, Director of NICT’s Beyond 5G Design Initiative Kentar Ishizu, and ITRI Research Consultant Mitch Tseng in this discussion moderated by SNS-JU Head of Programmes Javier Albares. More here.
The full 6GSymposium agenda and registration details can be found here.
About InterDigital ®
InterDigital is a global research and development company focused primarily on wireless, video, artificial intelligence (“AI”), and related technologies. We design and develop foundational technologies that enable connected, immersive experiences in a broad range of communications and entertainment products and services. We license our innovations worldwide to companies providing such products and services, including makers of wireless communications devices, consumer electronics, IoT devices, cars and other motor vehicles, and providers of cloud-based services such as video streaming. As a leader in wireless technology, our engineers have designed and developed a wide range of innovations that are used in wireless products and networks, from the earliest digital cellular systems to 5G and today’s most advanced Wi-Fi technologies. We are also a leader in video processing and video encoding/decoding technology, with a significant AI research effort that intersects with both wireless and video technologies. Founded in 1972, InterDigital is listed on Nasdaq.
InterDigital is a registered trademark of InterDigital, Inc.
For more information, visit: www.interdigital.com.
InterDigital Contact:
Roya Stephens
Email: Roya.Stephens@interdigital.com
+1 (202) 349-1714
Gamco
3 weeks ago
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
WESTERN DIVISION
Case No. 5:23-cv-00493-FL
INTERDIGITAL INC.,
INTERDIGITAL VC HOLDINGS, INC.,
INTERDIGITAL PATENT HOLDINGS,
INC., and INTERDIGITAL MADISON
PATENT HOLDINGS SAS,
Plaintiffs,
v.
LENOVO (UNITED STATES) INC.,
MOTOROLA MOBILITY LLC, and
LENOVO PC HK LIMITED,
Defendants.
LENOVO’S PARTIAL OBJECTION TO THE ORDER COMPELLING PRODUCTION
PURSUANT TO FED. R. CIV. P. 72(a)
Case 5:23-cv-00493-FL-RN Document 152 Filed 08/27/24 Page 1 of 9
1
I. INTRODUCTION
To ensure a complete examination of InterDigital’s licensing activities, Lenovo requests
that the Court modify one small, but critical part of the August 13, 2024 Order (“Order”). ECF
No. 145 at 3-5. On August 13, 2024, Magistrate Judge Numbers compelled InterDigital to
produce most of the discovery Lenovo requested. The Order denied Lenovo’s requested relief in
one key respect, however. The Order erroneously concluded that “offers that InterDigital has
made to others to license its patents are not relevant to the claims and defenses.” By narrowly
focusing on which demand would qualify under the statute as the bad-faith act, the Order
overlooked the core of Bad-Faith Factor 5. Bad Faith Factor 5 expressly compares InterDigital’s
bad-faith demand to Lenovo with InterDigital’s ostensibly good-faith demands to others (which
are likely to reflect “reasonable estimate[s] of the value of the license.”). N.C. Gen. Stat. § 75-
143(a)(5). Because good-faith offers that InterDigital has made to others to license its patents
reflect reasonable estimates of the value of the license, InterDigital’s offers to others are relevant
to the bad-faith offers InterDigital made to Lenovo. That makes these highly relevant offers
discoverable. Modification of the Order under Rule 72 is called for because the Order rests on a
misapplication of the law. Fed. R. Civ. P. 72(a). A proper application of Bad Faith Factor 5
must account for the comparison between the unlawful bad-faith offer to Lenovo and good-faith
offers to others. Discovery of these good-faith offers should be permitted.
II. LEGAL STANDARD
A. Review of Magistrate Judge Rulings
Under Fed. R. Civ. P. 72(a) and Local Rule 72.4(a) when a party timely objects to a
Magistrate Judge’s order, the District Court judge must consider “and modify or set aside any
part of [such] order found to be clearly erroneous or contrary to law.” Fed. R. Civ. P. 72(a). “A
factual finding is clearly erroneous when the [] court is left with the definite and firm conviction
Case 5:23-cv-00493-FL-RN Document 152 Filed 08/27/24 Page 2 of 9
2
that a mistake has been committed.” TFWS, Inc. v. Franchot, 572 F.3d 186, 188 (4th Cir. 2009).
“A ruling that is contrary to law is one where ‘the magistrate judge has misinterpreted or
misapplied applicable law.’” Jones v. Campbell Univ., No. 5:20-CV-29-BO, 2021 U.S. Dist.
LEXIS 134762, at *10 (E.D.N.C. July 19, 2021) (quoting Kounelis v. Sherrer, 529 F. Supp. 2d
503, 518 (D.N.J. 2008)). “‘Contrary to law’ indicates plenary review of legal conclusions,” i.e.,
review de novo. Vaitkuviene v. Syneos Health, Inc., No. 5:18-CV-29-FL, 2021 U.S. Dist. LEXIS
163473, at *17 (E.D.N.C. Aug. 30, 2021).
B. Scope of Discovery
A party “may obtain discovery regarding any nonprivileged matter that is relevant to any
party’s claim or defense.” Fed. R. Civ. P. 26(b)(1). Discovery rules are to be “accorded broad
and liberal treatment to effectuate their purpose that civil trials in the federal courts no longer
need be carried on in the dark.” Schlagenhauf v. Holder, 379 U.S. 104, 114-15 (1964). The
scope of discovery is broad. Beach Mart v. L&L Wings, No. 2:11-CV-00044-F, 2015 U.S. Dist.
LEXIS 201134, at *4 (E.D.N.C. May 5, 2015). When a party fails to answer an interrogatory or
to produce documents, the party seeking such discovery may move for an order compelling an
answer and production. Fed. R. Civ. P. 37(a)(3). The party opposing a motion to compel bears
the burden to demonstrate why discovery should not be granted. Silicon Knights, Inc. v. Epic
Games, Inc., 917 F. Supp. 2d 503, 533 (E.D.N.C. 2012), aff’d, 551 F. App’x 646 (4th Cir. 2014).
III. ARGUMENT
A. InterDigital’s Offers to License the Patents to Others Are Evidence of
InterDigital’s Own Good-Faith Estimate of Value for Bad Faith Factor 5
InterDigital’s good-faith estimates of the value of the Asserted Patents during licensing
negotiations with others is material to Lenovo’s NCAPAA counterclaim. Under the NCAPAA,
“t is unlawful for a person to make a bad-faith assertion of patent infringement,” which the
Case 5:23-cv-00493-FL-RN Document 152 Filed 08/27/24 Page 3 of 9
3
statute measures using twelve bad-faith factors. N.C. Gen. Stat. § 75-143(a). Central to
Lenovo’s counterclaim is Bad Faith Factor 5, which considers the bad-faith value of the
patentee’s licensing demand compared to the good-faith value of the patent license: “[t]he person
offers to license the patent for an amount that is not based on a reasonable estimate of the value
of the license . . . .” Id. § 75-143(a)(5).
Shortly after the Court denied InterDigital’s motion to dismiss Lenovo’s NCAPAA
counterclaim, Lenovo asked InterDigital to supplement responses to specific discovery requests
and produce documents related to the counterclaim, including Interrogatory No. 4. That
Interrogatory seeks, in part, a detailed description of InterDigital’s “efforts to license, or
otherwise exploit the Asserted Patents and/or Related Patents or Applications in the United
States.” ECF No. 108-9 (Lenovo’s Interrogatory No. 4). The Interrogatory also explains that a
complete response would include “all terms of such agreements, including all drafts, licensing
fees and/or licensing Rate[.]” Id. Because InterDigital refused to produce all responsive
information or respond fully to this interrogatory, Lenovo moved to compel. ECF No. 106. The
court granted nearly all of Lenovo’s requested relief, denying only discovery related to Bad Faith
Factor 5. ECF No. 145.
But the Order misunderstands Bad Faith Factor 5. The Order concludes that the focus of
Bad Faith Factor 5 is InterDigital’s unlawful bad-faith demand to Lenovo. Order at 5. While
that is part of Bad Faith Factor 5, it is not what is fully contemplated by the factor. It is true that
with respect to Bad Faith Factor 5, what matters is whether InterDigital made a bad-faith demand
to Lenovo. But that cannot be confirmed without knowing what good faith demands were made
to others. The text of Bad Faith Factor 5 confirms that additional information can be used to
determine whether InterDigital’s offer to Lenovo was in bad faith. Factor 5 considers the value
Case 5:23-cv-00493-FL-RN Document 152 Filed 08/27/24 Page 4 of 9
4
of the patentee’s licensing demand relative to the value of the patent license: “[t]he person offers
to license the patent for an amount that is not based on a reasonable estimate of the value of the
license[.]” Id. § 75-143(a)(5). The plain language of the factor compares the value of
InterDigital’s unlawful bad-faith demand to Lenovo against “a reasonable estimate of the value
of the license,” i.e., good-faith valuations. Id. While the factor is focused on InterDigital’s bad-
faith demand to Lenovo the Order erred by not considering that InterDigital’s good-faith offers
to others informs the factor’s the comparison—the “reasonable estimate of the value of the
license.” Id. Because of this misapplication, the Order prevents Lenovo from juxtaposing
InterDigital’s bad-faith demand to Lenovo with InterDigital’s ostensibly good-faith offers to
others.
InterDigital’s good-faith offers to others are probative of the “reasonable estimate of the
value of the license” and are thus discoverable. “A discovery request is relevant if there is any
possibility that the information sought might be relevant to the subject matter of [the] action.”
Hicks v. Hous. Baptist Univ., No. 5:17-CV-629-FL, 2020 U.S. Dist. LEXIS 8382, at *5
(E.D.N.C. Jan. 17, 2020). Properly applies, InterDigital’s good-faith offers to others bear on Bad
Faith Factor 5 because those offers reflect the value of the license. See, e.g., Curtis Mfg. Co. v.
Plasti-Clip Corp., 933 F. Supp. 94, 100 (D.N.H. 1995) (“One such factor is the prior or existing
royalties received by the patentee for the licensing of the patent in question. Related to this factor
is evidence of prior offers to license by the patentee.”); 6A Chisum on Patents § 20.03 (2024)
(“If the owner chooses to exploit the patent through offering licenses at an established royalty
rate, that rate is the appropriate basis for recovery.”). The Federal Circuit has held that even
“license proposals,” which are akin to InterDigital’s offers to others, “should carry considerable
weight in calculating a reasonable royalty” and may be relevant to determining a reasonable
Case 5:23-cv-00493-FL-RN Document 152 Filed 08/27/24 Page 5 of 9
5
royalty. Unisplay, S.A. v. Am. Elec. Sign Co., 69 F.3d 512, 519 (Fed. Cir. 1995). InterDigital’s
good-faith offers to license the Asserted Patents to others are thus probative of the Bad Faith
Factor 5’s inquiry into the “reasonable estimate of the value of the license.” The Court should
therefore modify the Order and compel InterDigital to produce all offers to license the Asserted
Patents in negotiations with others.
B. Modification of the Order to Compel InterDigital to Produce Valuations of
the Asserted Patents in Negotiations with Others is Warranted
Modification of the Order under Fed. R. Civ. P. 72(a) and Local Rule 72.4(a) is
appropriate here because the Order “misapplied applicable law.” Jones, No. 5:20-CV-29-BO,
2021 U.S. Dist. LEXIS 134762, at *10. The Order correctly observes (at 3), that when called
upon to interpret a North Carolina statute, the Court must use the interpretative methodology set
out by the North Carolina Supreme Court. See Wynn v. Frederick, 385 N.C. 576, 581, 895
S.E.2d 371, 377 (2023); see also Wells v. Liddy, 186 F.3d 505, 528 (4th Cir. 1999). The
interpretative framework in North Carolina is purposivism. See Whitmire v. Southern Farm
Bureau Life Ins., 52 F.4th 153, 157 (4th Cir. 2022). The North Carolina Supreme Court
explained how courts should apply purposivism to interpret state statutes: “courts should always
seek to give effect to the legislative intent, which may be discerned by consideration of the
purpose of the statute, ‘the evils it was designed to remedy, the effect of proposed interpretations
of the statute, and the traditionally accepted rules of statutory construction.’” State v. Gaines,
332 N.C. 461, 469, 421 S.E.2d 569, 572 (1992) (quoting State v. Tew, 326 N.C. 732, 738, 392
S.E.2d 603, 607 (1990)). The goal of this methodology is “to determine the meaning that the
legislature intended upon the statute’s enactment.” State v. Rankin, 371 N.C. 885, 889, 821
S.E.2d 787, 792 (2018). The intention of the legislature is derived “from the plain language of
the statute, then from the legislative history, the spirit of the act and what the act seeks to
Case 5:23-cv-00493-FL-RN Document 152 Filed 08/27/24 Page 6 of 9
6
accomplish.” Id. And “where [a] statute is ambiguous or unclear as to its meaning, the courts
must interpret the statute to give effect to the legislative intent.” Frye Reg’l Med. Ctr., Inc. v.
Hunt, 350 N.C. 39, 45, 510 S.E.2d 159, 163 (1999).
The Order correctly looks first to the plain words of the Bad Faith Factor 5 to determine
the legislature’s intent. Order at 3. But it erred when it concluded that the plain language of Bad
Faith Factor 5 requires the bad-faith factor to be conducted in a vacuum—without reference to
any evidence of what the defendant considers to be a good-faith offer to others. Id. The plain
words of Bad Faith Factor 5 consider the value of the patentee’s licensing demand relative to a
reasonable estimate of the value of the patent license: “[t]he person offers to license the patent
for an amount that is not based on a reasonable estimate of the value of the license[.]” Id. § 75-
143(a)(5). The plain language, therefore, contemplates comparison of InterDigital’s demand of
Lenovo with other “reasonable estimate[s] of the value of the license,” which includes
InterDigital’s own good-faith offers to license the Asserted Patents in negotiations with others.
Id. Lenovo should be able to compare InterDigital’s bad-faith demand to Lenovo with
InterDigital’s good-faith demand to others. Because the plain language of Bad Faith Factor 5
unambiguously considers a comparison between InterDigital’s demand of Lenovo and other
estimates of the value of a license, the Order should have applied the factor as written and
allowed discovery into the offers made by InterDigital to others. Wynn, 385 N.C. at 581; see
also Eisenbise v. Crown Equip. Corp., No. 15-CV-972-AJB-WVG, 2015 U.S. Dist. LEXIS
194898, at *6 (S.D. Cal. Dec. 4, 2015) (holding “misapplication of the Federal Rules” was
subject to de novo review). InterDigital’s good-faith representations about the value of the
Asserted Patents in negotiations with others are highly relevant to Bad Faith Factor 5 and thus
InterDigital should be compelled to produce them.
Case 5:23-cv-00493-FL-RN Document 152 Filed 08/27/24 Page 7 of 9
7
IV. CONCLUSION
For reasons above, the Court should modify the Order and compel InterDigital to
produced the valuations of the Asserted Patents in negotiations with others.
Dated: August 27, 2024 Respectfully submitted,
By: /s/ Raymond M. Bennett
Raymond M. Bennett (NC Bar No. 36341)
WOMBLE BOND DICKINSON (US) LLP
555 Fayetteville Street, Suite 1100
Raleigh, NC 27601
Tel: (919) 755-2158
Fax: (919) 755-6068
Ray.Bennett@wbd-us.com
Jacob S. Wharton (NC Bar No. 37421)
WOMBLE BOND DICKINSON (US) LLP
One West 4th St.
Winston-Salem, NC 27601
Tel: (919) 747-6609
Jacob.Wharton@wbd-us.com
Adam Shartzer
FISH & RICHARDSON P.C.
1000 Maine Ave SW
Washington, D.C. 20024
Tel: (202) 626-6380
shartzer@fr.com
Special Appearance Pursuant to L.R. 83.1
Jack R. Wilson IV
FISH & RICHARDSON P.C.
1000 Maine Ave SW
Washington, D.C. 20024
Tel: (202) 626-6415
jwilson@fr.com
Special Appearance Pursuant to L.R. 83.1
Attorneys for Defendants
Lenovo PC HK Limited, Lenovo (United States)
Inc., and Motorola Mobility LLC
Case 5:23-cv-00493-FL-RN Document 152 Filed 08/27/24 Page 8 of 9
8
CERTIFICATE OF SERVICE
I hereby certify that on August 27, 2024, the foregoing document was served upon all
counsel of record via the CM/ECF system.
/s/ Raymond M. Bennett
Raymond M. Bennett
Case 5:23-cv-00493-FL-RN Document 152 Filed 08/27/24 Page 9 of 9
dws
3 weeks ago
InterDigital to Showcase Excellence in Broadcast and Immersive Video Solutions at IBC 2024
Company Release - 8/29/2024
InterDigital innovation impact on display alongside industry partners and collaborators at Ultra HD Forum, 5G-MAG Insights, and CSI Awards
WILMINGTON, Del., Aug. 29, 2024 (GLOBE NEWSWIRE) -- InterDigital, Inc. (Nasdaq: IDCC), a mobile, video and AI technology research and development company, will showcase state-of-the-art video innovation at the International Broadcasting Convention (IBC), taking place in Amsterdam from September 13 – 16. InterDigital will demonstrate at IBC alongside partners at the Ultra HD Forum, IABM lounge, and 5G-MAG Insights Tech Conference to amplify the impact of immersive video codecs and implementations of Advanced HDR by Technicolor solutions that empower consistent, high-quality HDR content delivery across devices and markets.
Jointly developed by InterDigital and Philips, Advanced HDR by Technicolor® is a suite of High Dynamic Range (HDR) production, distribution and display solutions that maximize image quality and enhance the consumer viewing experience. Our contributions to the Advanced HDR solutions offer the only HDR streaming format that brings HDR to consumers without any bitrate penalty or change to the standard dynamic range (SDR) workflow. At IBC, InterDigital and Philips will showcase the increasingly important role Advanced HDR solutions play in efficiently broadcasting HDR content across diverse distribution formats.
Experience the Demos at Ultra HD Forum and IABM
At the Ultra HD Forum booth in Hall 3, #B.21, InterDigital will highlight the advantages of Advanced HDR by Technicolor solutions for the Advanced Television Systems Committee (ATSC) and Brazil's Sistema Brasileiro de Televisão Digital (SBTVD) Forum. Advanced HDR by Technicolor is the only solution currently providing continuous, live HDR content via ATSC 3.0 stations -- also known as NEXTGEN TV -- across the U.S., and it has been included in the SBTVD TV 2.5 and TV 3.0 standards in Brazil. Advanced HDR by Technicolor, Fraunhofer and Hisense participated in a showcase held by Globo -- one of the largest media companies in Brazil and Latin America -- during the Paris games held this summer. InterDigital, along with Ateme, Fraunhofer, and Hisense, will jointly demonstrate encoder and display-side solutions for implementing SBTVD standards using cutting-edge technologies, such as MPEG-H, AVC, HDR, Advanced HDR by Technicolor, and VVC.
At the IABM room, InterDigital will showcase our Advanced HDR solutions offering the only Single Master Workflow. These solutions ensure automatic and tunable dynamic SDR to HDR and HDR to SDR conversions to sustain all distribution formats, which could be critical for sports and other emerging use cases. InterDigital will display the latest implementations of Advanced HDR solutions in European live sport events and live content distribution in U.S. markets.
Hear Us Present at 5G-MAG Insights
In addition to demos, InterDigital’s Valerie Allie will highlight the merits of our MPEG Visual Volumetric Video-based Coding (V3C) Immersive Platform to support the delivery of volumetric video experiences at the 5G-Media Action Group (5G-MAG) Insights Networking and Tech Conference. The presentation will take place on Friday, September 13 from 16:00 – 17:00.
InterDigital’s V3C Immersive Platform, developed alongside Philips, was recently contributed to the 5G-MAG Reference Tools to visualize, test, and demonstrate volumetric content, while supporting real-time V-PCC and MPEG Immersive Video MIV rendering on devices. 5G-MAG Reference Tools is an open-source repository that helps developers leverage standardized volumetric video technologies to explore the creation of new immersive content. Learn more and register to attend here.
Recognize Our Innovation Impact at the CSI Award
InterDigital has been shortlisted for three CSI Awards, recognizing our excellence in video processing, innovation in immersive video experiences, and solutions to mitigate the energy impact of the video value chain. Specifically, InterDigital has been shortlisted for an award recognizing Best Immersive Video for our contributions to MPEG V3C and Haptics standards, an award recognizing Best Sustainability Project or Initiative for our leading-edge research on pixel value reduction innovation and other energy-efficient solutions, and an award celebrating Best Video Processing Technology for our contributions to Advanced HDR by Technicolor solutions.
The CSI awards will be announced at IBC on September 13. Learn more about the InterDigital innovation that earned this recognition here.
To register and learn more about IBC, please click here.
About InterDigital ®
InterDigital is a global research and development company focused primarily on wireless, video, artificial intelligence (“AI”), and related technologies. We design and develop foundational technologies that enable connected, immersive experiences in a broad range of communications and entertainment products and services. We license our innovations worldwide to companies providing such products and services, including makers of wireless communications devices, consumer electronics, IoT devices, cars and other motor vehicles, and providers of cloud-based services such as video streaming. As a leader in wireless technology, our engineers have designed and developed a wide range of innovations that are used in wireless products and networks, from the earliest digital cellular systems to 5G and today’s most advanced Wi-Fi technologies. We are also a leader in video processing and video encoding/decoding technology, with a significant AI research effort that intersects with both wireless and video technologies. Founded in 1972, InterDigital is listed on Nasdaq.
InterDigital is a registered trademark of InterDigital, Inc.
For more information, visit: www.interdigital.com.
InterDigital Contact:
Roya Stephens
Email: roya.stephens@interdigital.com
+1 (202) 349-1714
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